Presentation is loading. Please wait.

Presentation is loading. Please wait.

U.S. Environmental Protection Agency

Similar presentations


Presentation on theme: "U.S. Environmental Protection Agency"— Presentation transcript:

1 Overview: The Spill Prevention, Control, and Countermeasure (SPCC) Guidance for Regional Inspectors
U.S. Environmental Protection Agency Office of Solid Waste and Emergency Response Office of Emergency Management

2 SPCC Guidance Document
Is intended to assist regional inspectors in reviewing a facility’s implementation of the SPCC rule Establishes a consistent understanding among regional EPA inspectors on how particular provisions of the rule may be applied Available as a guide to owners and operators of facilities and the general public This slideshow presents an overview of the topics covered in the Guidance Document. The full document is available at Overview: SPCC Guidance for Regional Inspectors

3 Disclaimer The statutory provisions and EPA regulations described in this guidance document contain legally binding requirements. The guidance document does not substitute for statutory provisions or regulations, nor is it a regulation itself. While the guidance document indicates EPA's strongly preferred approach to assure effective implementation of legal requirements, EPA decisionmakers retain the discretion to adopt approaches on a case-by-case basis that differ from this guidance where appropriate. EPA welcomes public comments on the document at any time and will consider those comments in any future revision of the guidance document. Overview: SPCC Guidance for Regional Inspectors

4 Guidance Document Contents
Chapter 1: Introduction Chapter 2: Applicability of the SPCC Rule Chapter 3: Environment Equivalence Chapter 4: Secondary Containment and Impracticability Determinations Chapter 5: Oil/Water Separators Chapter 6: Facility Diagrams Chapter 7: Inspection, Evaluation, and Testing Appendices Overview: SPCC Guidance for Regional Inspectors

5 Chapter 1: Introduction
SPCC Background Purpose and scope Statutory framework Regulatory History Initial promulgation Proposed revisions Overview of 2002 Revised Rule Provisions Using the Guidance Document Overview: SPCC Guidance for Regional Inspectors

6 Using the Guidance Document
Clarifies the role of the inspector in reviewing implementation of performance-based provisions Is a “living document” and may be updated or revised Does not address all aspects of the SPCC rule Overview: SPCC Guidance for Regional Inspectors

7 Chapter 2: Applicability
Applicability criteria: Definition of “oil” and activities involving oil Definition of “facility” “Non-transportation-related” facilities – EPA/DOT jurisdiction Definition of “discharge” Reasonable expectation of discharge to navigable waters in quantities that may be harmful Regulated storage capacity Various exemptions Overview: SPCC Guidance for Regional Inspectors

8 Applicability, continued
Regional Administrator Process for an RA to apply the SPCC rule to an otherwise exempted facility Appeals process Different types of containers Bulk storage containers and oil-filled equipment Applicability of facility response plan requirements Overview: SPCC Guidance for Regional Inspectors

9 Summary of SPCC Applicability

10 Chapter 3: Environmental Equivalence
The “environmental equivalence” provision allows facilities to implement alternate measures based on site-specific considerations Measures must provide equivalent environmental protection, in accordance with good engineering practice and as determined by a Professional Engineer. Lists the substantive requirements eligible for the provision, clarifies certain policy areas, and provides examples Describes the role of EPA inspector in reviewing deviations based on environmental equivalence Overview: SPCC Guidance for Regional Inspectors

11 Environmental Equivalence, continued
Additional guidance on environmentally equivalent measures for specific requirements: Security Facility drainage Corrosion protection and leak testing of completely buried metallic storage tanks Overfill prevention Piping Evaluation, inspection, and testing Overview: SPCC Guidance for Regional Inspectors

12 Chapter 4: Secondary Containment and Impracticability Determinations
Overview of secondary containment provisions Example methods of containment General vs. specific provisions Sufficient freeboard Sample calculations of containment sizing Passive vs. active measures Examples of when each approach may be appropriate “Sufficiently impervious” Facility drainage requirements Overview: SPCC Guidance for Regional Inspectors

13 Categories of Secondary Containment Requirements
General Provision, §112.7(c) Addresses the potential for oil discharges from all regulated parts of a facility Containment method, design, and capacity are determined by good engineering practice to contain an oil discharge until clean-up occurs. Specific Provisions Address the potential of oil discharges from specific parts of a facility where oil is stored or handled. Containment design, sizing, and freeboard requirements are specified by the SPCC rule to address a major container failure. Overview: SPCC Guidance for Regional Inspectors

14 Impracticability Determinations
Additional requirements that accompany an impracticability determination Documentation needed Detail on impracticability determinations for certain areas: Piping and flowlines Transfer areas Oil-filled Equipment Loading/unloading racks Onshore bulk storage containers Mobile/portable containers Bulk storage containers at production facilities Onshore drilling and workover equipment Overview: SPCC Guidance for Regional Inspectors

15 Chapter 5: Oil/Water Separators
Provides applicable SPCC requirements for oil/water separators used for: Wastewater treatment Secondary containment Oil production Overview: SPCC Guidance for Regional Inspectors

16 SPCC Requirements for Oil/Water Separator Uses
Wastewater Treatment Use Secondary Containment Use Oil Production Use Separators are exempt from all SPCC requirements in accordance with §112.1(d)(6) and do not count toward facility storage capacity. Separators which are used as part of a secondary containment system and are not intended for oil storage or use are subject to applicable secondary containment requirements and do not count toward storage capacity. Separators are bulk storage containers, subject to the provisions of §§112.9(c) or (d), and count toward the overall facility storage capacity. They are not exempt. Overview: SPCC Guidance for Regional Inspectors

17 Chapter 6: Facility Diagrams
This chapter discusses: The purpose of the facility diagram Required and recommended elements of a facility diagram Necessary level of detail Approaches for specific types of equipment Provides example facility diagrams Overview: SPCC Guidance for Regional Inspectors

18 Chapter 7: Inspection, Evaluation, and Testing
Overview of the inspection, evaluation, and testing requirements Specific requirements for: Integrity testing and visual inspection Brittle fracture evaluation Inspections of piping Flowline maintenance Overview: SPCC Guidance for Regional Inspectors

19 Inspection, Evaluation, and Testing, continued
Specific cases Aboveground bulk storage container for which the baseline condition is known Aboveground bulk storage container for which the baseline condition is not known Deviation from integrity testing requirements based on environmental equivalence Summary of industry standards, code requirements, and recommended practices that apply to different types of equipment Overview: SPCC Guidance for Regional Inspectors

20 Role of the EPA Inspector
Each chapter describes: Appropriate documentation that the owner/operator should include in SPCC Plan What EPA inspectors should look for both in the Plan and in the field to determine compliance with the SPCC rule If the inspector questions the appropriateness of alternative measures, he/she should fully document all observations and other pertinent information for further review by the regional staff. Follow-up action by the EPA inspector may include requesting additional information from the facility owner or operator. Overview: SPCC Guidance for Regional Inspectors

21 Appendices Text of CWA 311(j)(1)(c) Text of 40 CFR Part 112
Summary of Revised Rule Provisions Sample Bulk Storage Facility SPCC Plan Sample Production Facility SPCC Plan Sample Contingency Plan SPCC Inspection Checklists Other Policy Documents Overview: SPCC Guidance for Regional Inspectors

22 Sample Plans Example SPCC Plans for bulk storage and oil production facilities Show appropriate format and level of detail Can be adapted to fit a facility’s site-specific characteristics Example Contingency Plan Prepared according to the requirements of 40 CFR part 109 Overview: SPCC Guidance for Regional Inspectors

23 SPCC Inspection Checklists
For EPA inspectors to record observations during the site visit and review of the SPCC Plan Provides room for inspector comments and photos of the facility Helps achieve the goal of national consistency in inspections Overview: SPCC Guidance for Regional Inspectors

24 Additional Information
The Guidance Document and additional information is available on the U.S. EPA Oil Program Web site, Call the TRI, EPCRA, RMP and Oil Information Call Center at Overview: SPCC Guidance for Regional Inspectors


Download ppt "U.S. Environmental Protection Agency"

Similar presentations


Ads by Google